Privacy Policy

As a registered investment adviser, Invictus Capital Partners must comply with SEC Regulation S-P as administered and enforced by the Federal Trade Commission, which requires registered advisers to adopt policies and procedures to protect the "non-public personal information" of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information.

Regulation S-P / Privacy Rule
The purpose of these regulatory requirements and privacy policies and procedures is to provide administrative, technical and physical safeguards which assist employees in maintaining the confidentiality of non-public personal information ("NPI") collected from the consumers and customers of an investment adviser. All NPI, whether relating to an adviser's current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.

For these purposes, NPI includes non-public "personally identifiable financial information" plus any list, description or grouping of customers that is derived from non-public personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Invictus Capital Partners to clients, and data or analyses derived from such NPI.

The Firm is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Invictus Capital Partners' client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations.

Invictus Capital Partners has adopted various procedures to implement the firm's policy and conducts reviews to monitor and ensure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Non-Disclosure of Client Information
Invictus Capital Partners maintains safeguards to comply with federal and state standards to guard each client's non-public personal information ("NPI"). Invictus Capital Partners does not share any NPI with any nonaffiliated third parties, except in the following circumstances:

Employees are prohibited, either during or after termination of their employment, from disclosing NPI to any person or entity outside Invictus Capital Partners, including family members, except under the circumstances described above. An employee is permitted to disclose NPI only to such other employees who need to have access to such information to deliver our services to the client.

Safeguarding and Disposal of Client Information
Invictus Capital Partners restricts access to NPI to those employees who need to know such information to provide services to our clients.

Any employee who is authorized to have access to NPI is required to keep such information in a secure compartments or receptacle annually. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving NPI, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Safeguarding standards encompass all aspects of the Invictus Capital Partners that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that Invictus Capital Partners may adopt include:

Any employee who is authorized to possess "consumer report information" for a business purpose is required to take reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal. There are several components to establishing 'reasonable' measures that are appropriate for the firm:

Some methods of disposal to ensure that the information cannot practicably be read or reconstructed that Invictus Capital Partners may adopt include:

Privacy Notices
Where regulatory required, Invictus Capital Partners will provide each natural person client with initial notice of the firm's current policy when the client relationship is established. Invictus Capital Partners shall also provide each such client with a new notice of the firm's current privacy policies at least annually.

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Management Team

Michael Warden has more than 27 years of capital markets experience with an extensive focus on the mortgage sector. He is the managing principal and CEO of Invictus Capital Partners, which was selected as the joint venture partner and manager for all Carlyle Real Estate debt strategies in 2008. In that role, Mr. Warden managed the investment of more than $2 billion in equity capital. Prior to forming Invictus, Mr. Warden was a senior managing director and head of Fixed Income at Friedman, Billings, Ramsey & Co. (FBR). At FBR, he was responsible for the establishment and build out of the fixed income business for which he developed an origination, banking, sales and trading platform. He also was instrumental in the acquisition and integration of a mortgage origination company. Within two years the business underwrote in excess of $30 billion in MBS securities and originated, purchased and securitized over $8 billion in whole loans. Previously, Mr. Warden was managing director and head of ABS and CMBS at Bank of America Securities (BOA), where he was responsible for the origination and securitization of all mortgage products. At BOA, he was integral in the establishment of both the ABS and CMBS businesses.

Robert Konigsberg has more than 27 years of experience and serves as COO and CFO of Invictus Capital Partners. Prior to joining Invictus, Mr. Konigsberg was a managing director at The Carlyle Group. During his 15-year tenure at Carlyle, Mr. Konigsberg served as the Chief Financial Officer of Carlyle’s Real Assets segment, which represented approximately $30 billion of assets under management across real estate, energy and infrastructure. Mr. Konigsberg’s responsibilities at Carlyle included oversight for all aspects of fund/partnership compliance, controls, investor reporting, interest rate and currency hedging, oversight of quarterly valuation processes, negotiation of numerous fund-level subscription and asset-backed credit facilities, SEC segment reporting and segment budgeting and forecasting. In addition, Mr. Konigsberg was instrumental in the execution and structuring of more than 250 investment acquisitions and more than 100 exits, with the objectives to structure efficiently for tax, ERISA and divestiture. Mr. Konigsberg was also responsible for developing fund terms and structures with investors, including public and government pension funds, corporate pension funds, endowments, banks, insurance companies, high net worth individuals and feeder funds. Prior to joining Carlyle in 1999, Mr. Konigsberg was a senior manager with Arthur Andersen, where he served real estate and financial services clients. Mr. Konigsberg is a graduate of the Kogod School of Business at American University.

Dane Smith is a founding member of Invictus Capital Partners, with 13 years of mortgage finance and capital markets experience. Mr. Smith oversees all research and analytics, and is responsible for identifying and sourcing new investment opportunities. He is instrumental in creating and implementing the analytical framework and models that Invictus uses to analyze and predict the performance of mortgage credit for both residential securities and whole loan investments. Prior to Invictus, Mr. Smith worked at Friedman, Billings, Ramsey, & Co. (FBR) as vice president of Investment Banking. At FBR, Mr. Smith helped create all analytics processes and tools for mortgage collateral and security analysis for principal investment, and was responsible for managing all aspects of mortgage backed securitization finance for both principal and third party transactions. Mr. Smith’s securitization responsibilities at FBR included collateral analysis, security structuring, rating agency coordination, due diligence, investor marketing and deal documentation review. Mr. Smith started his career as an analyst at Wachovia Securities in the Investment Banking Asset Securitization group. Mr. Smith received a B.E., magna cum laude, from Vanderbilt University, with dual majors in Chemical Engineering and Mathematics.

Peter Zimmer is head of Capital Markets at Invictus Capital Partners, with more than 14 years of mortgage finance experience. He has been essential in the selection and pricing of more than $2 billion in RMBS credit since 2008. Previously, Mr. Zimmer was vice president of Whole Loan Trading at Friedman, Billings, Ramsey, & Co. (FBR), where he built the whole loan acquisition platform necessary to trade whole loans and manage an RMBS portfolio. While at FBR, Mr. Zimmer purchased and managed a portfolio in excess of $6 billion in residential whole loans. Among Mr. Zimmer’s responsibilities were valuation, management and pricing of mortgage product offerings at FBR’s wholly-owned, mortgage originator. Prior to joining FBR, Mr. Zimmer was a whole loan trader at GMAC-RFC in Minneapolis, where he was responsible for the pricing and acquisition of both prime and non-prime whole loan pools. Mr. Zimmer is a graduate of the University of North Dakota from which he earned a degree in financial management.

Carl Bell is a lead investor with Invictus Capital Partners with over 24 years of institutional asset management experience. Mr. Bell is focused on the identification, sourcing, and management of credit investments drawn from the full spectrum of consumer, real estate, and corporate obligations. Mr. Bell has developed substantial sector expertise in the area of structured credit instruments, including high yield and distressed real estate credit. Previously, Mr. Bell co-founded Five Ten Capital, an alternative asset manager focused on deploying equity and debt capital into the single-family rental market segment. Five Ten was subsequently sold to a large mortgage and real estate investor. He has also served as a Senior Portfolio Manager and Team Leader for Structured Credit for both Amundi Smith Breeden (“ASB”) and Putnam Investments. At ASB he had the additional responsibility of Deputy Chief Investment Officer. Mr. Bell holds an MBA from The Fuqua School of Business, Duke University where he was a Fuqua Scholar and received the James G. Hanes Scholarship. He earned a BS in Mathematics at Carnegie Mellon University.